U.S. Department of Transportation

Pipeline and Hazardous Materials Safety Administration

APR 0 2 2015

Mr. Jeremy Copeland, CHMM Environmental Manager Wacker Polysilicon North America, LLC PO Box 446 Charleston, TN 3 7310

Dear Mr. Copeland:

1200 New Jersey Ave, S.E. Washington, D.C. 20590

In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated January 12, 2015, you requested an interpretation of the applicability of the 49 CFR Parts 192 and 195 requirements to your pipelines.

You stated that Wacker Polysilicon Notih America. LLC (Wacker) is constructing a chemical plant in Charleston, TN. Inc! uded in the plant is the construction of two dedicated chemical pipelines that will transport chlorine gas and sodium hydroxide liquid from Olin Corporation (where the chemicals are manufactured) to Wacker's facility. The overall length of the aboveground pipeline for both the chlorine gas and sodium hydroxide is approximately 5,000 feet. You stated that the pipelines cross underneath a county road through an open-to-air box culvert that separates the two facilities (map provided). You asked for an interpretation as to the applicability of PHMSA regulations to your pipelines.

You stated that § 192.1 does not appear to exclude the chlorine pipeline. It is your belief that because chlorine gas is both toxic and corrosive. the chlorine pipeline may be regulated under Part 192.

As to the sodium hydroxide pipeline, you stated that§ 195.1 provides exclusions and you believe § 195.l(b)(3)(ii) exempts the sodium hydroxide line because; (1) the length of line measured outside of facility grounds is less than one mile; (2) the pipeline serves a manufacturing facility: and (3) the pipeline does not cross a waterway used for commercial navigation. Therefore, it is your belief that the sodium hydroxide pipeline is not regulated under Part 195.

Pmi 192 prescribes minimum safety requirements for pipeline facilities and the transportation of gas. including pipeline facilities and the transportation of gas within the limits of the outer continental shelf(§ 192.1 ). Also, § 192.3 defines the term ''gas" as natural gas. i1ammable gas. or gas which is toxic or corrosive. Therefore, as you stated in your request letter, the transportation of chlorine gas is regulated under Part 192 regulations.

Part 195 prescribes minimum safety standards and reporting requirements for pipeline facilities used in the transportation of hazardous liquids or carbon dioxide. Section 195.2 defines

The Pipeline and Hazardous Materials Safety Administration. Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the public understand how to comply with the regulations.

hazardous liquids as petroleum, petroleum products, or anhydrous ammonia. Therefore, transportation of hazardous liquids by pipeline that is not petroleum, petroleum products, or anhydrous ammonia (in this case sodium hydroxide) is not regulated under Part 195.

Ifwe can be offurther assistance, please contact Tewabe Asebe of my staff at 202-366-5523.

Sincerely,

Director, Office of Standards and Rulemaking

The Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the public understand how to comply with the regulations.

2

!WACKER II POLYS ILl co Nl

Wacker Polysilicon North America LLC

Office of the Chief Counsel U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave., SE East Building, 2nd Floor Washington, DC 20590-0001 e-version delivered to phmsa.hm-pipelinesafety@dot.gov hardcopy_ via Fed Ex, trackin' no. 77Z.> S7..3<j 4£/. 0

January 12, 2015

JEREMY COPELAND P-EHICHA

Wacker Polyslllcon North America LLC 553 McBryan! Road Charleston, TN 37310-0446, USA Tel. +1 423 780 7953 Fax +1 517 264 4021 jeremy.copeland@wacker.com P. 0. Box446 Charleston, TN 37310-0446, USA

0 As discussed

0 Thank you

0 To be kept on file

Requested action:

0 For your information

181 For review and comment

0 Take appropriate action

0 Contactme

0 Please return

Re: Regulatory Jurisdiction Request, Wacker Polysilicon North America, LLC; Charleston, TN

Dear Sir or Madam:

Wacker Polysilicon North America, LLC (Wacker) is constructing a chemical plant in Charleston, TN located at 553 McBryant Road NW, Charleston, TN 37310. Included in the plant is the construction of two, dedicated chemical pipelines that will transport chlorine gas and sodium hydroxide liquid from Olin Corporation (where the chemicals are manufac­tured) to Wacker's facility. The overall length of the aboveground pipeline is approximately 5,000 feet and it crosses underneath a county road (through an open to air box culvert) that separates the two facilities. Please refer to Appendix A that provides an aerial view of the route of the pipelines.

Chlorine

The scope of Title 49 CFR Part 192.1 includes pipelines that transport gas. Some exclu­sions are listed in the rule, but none that appear to exclude the chlorine pipeline. It is Wacker's interpretation that the chlorine pipeline may be regulated under 49 CFR part 192; based primarily on the fact that chlorine gas is both toxic and corrosive.

Sodium Hydroxide

The scope of Title 49 CFR Part 195.1 includes pipelines that transport hazardous liquid. Wacker interprets that the exclusion listed in 49 CFR Part 195.1 (b )(3)(ii) exempts the sodi­um hydroxide line because; (1) the length of line measured outside of facility grounds is less than one mile, (2) the pipeline serves a manufacturing facility, and (3) the pipeline does not cross a waterway used for commercial navigation. Therefore, Wacker concludes

that the sodium hydroxide pipeline is not regulated by the Federal Department of Transpor­tation (USDOT).

As requested by USDOT personnel and pursuant to 49 CFR 190.11 (b); Wacker is request­ing written regulatory interpretation of the US DOT regulatory jurisdiction/PHMSA rules ap­plicability to each of the the Wacker pipelines described above. Please refer to our user ID application request already filed with PHMSA and attached as Appendix B. This applica­tion was filed in June 2014 based on our own rule interpretation that the chlorine line is regulated. Since filing the application request, Wacker inquired to USDOT as to the status of the processing of the application and we were directed to send this regulatory interpreta­tion request to the Office of Chief Counsel.

If you have any questions necessary to provide clarifications or aid in processing our re­quest or would like to discuss the topics for any reason, please contact me at (423) 780-7953. You may return your response to Wacker either electronically at: Jeremy.Copeland@wacker.com or via hardcopy to: Jeremy Copeland, Environmental Manager, Wacker Polysilicon North America, PO Box 446, Charleston, TN 37310.

Cordially,

Jeremy Copeland, CHMM Environmental Manager Wacker Polysilicon North America, LLC

APPENDIX A

Aerial Layout

APPENDIX B

OPID Assignment Request

Notice: This report is required by 49 CFR Parts 191 and 195. Failure lo report may resul t in a civil penalty nollo exceed $100,000 for each viola tion for each day the violation continues up to a max imum of$1,000,000 as provided in 49 USC 60122.

Form Approved OMB o. 213 7-0627

Expiration Dale: 12/31/2014

~' U.S. Department of Transportation I ~W Pipeline and Hazardous Materials Safety

Administration

OPID ASSIGNMENT REQUEST

I DOT USE ONLY

A federa l agency may not conduct or sponsor, and a person is not required to respond to, nor shall a person be subject to a penalty for faiJw·e to comply with a collection of infonnation subject to the requirements of the Paperwork Reduction Act unless that co llection of info!Ulation displays a current va lid OMB Control Number. The OMB Contro l Number for this inf01mation co ll ection is 2137-0627. Public reporting for this collection of information is estimated to be approximately 60 minutes per response, including the time for reviewing instructions, gathering the data needed, and completing and reviewing the collection of information. All responses to tltis collection of infom1ation are mandatory. Send comments regarding tltis burden estimate or any other aspect of tl1is collection of information, including suggestions for reducing this burden to: lnformation Co llection Clearance Officer, PHMSA, Office of Pipeline Safety (PHP-30) 1200 New Jersey Avenue, SE, Washington , D.C. 20590.

STEP 1 - ENTER BASIC REPORT INFORMATION I Date of this OPID Assignment Request:

Month Day Year 1. Are the pipelines and/or facilities covered by this OPID Assignment Request subject to regulation under all or any part of 49 CFR Parts 191 ,

192, 193 , 194, and/or1 95?

~ Yes

D No --> No Further action needed.

2. Are the pipelines and/or faci lities covered by this OPID Assignment Request:

0 Newly constructed pipelines and/or facili ties

--> Approximate start date of construction: 07 14 14 Month Day Year

--> Anticipated date of operational start-up: 04 01 15 Month Day Year

0 Existing pipelines and/or facilities --> 2a. Were they previously operated under another OPID?

No

Yes-> 2b. Is the Previous OPID Number known?

0 No

0 Yes - > List Previous OPID Number: Previous Operator name:

3. Name of Operator as you would like it to appear in PHMSA records: WACKER POL YSILICON NORTH AMERICA. LLC

4. Operator Headquarters address: 553 MCBRYANT RD. , PO BOX 446

City: CHARLESTON State/Province: TN Zip/Postal Code: 37310

5. Name of Operator contact for this OPID Assignment Request:

Last: Copeland First: Jeremy Ml: Q

6. Phone number of Operator contact for this OPID Assignment Request: !423)780-7953

7. Is th is Operator a wholly owned subsidiary of another company?

0 No

~ Yes ->Company name: W acker-Chemie Achte Ventu re GmbH

[End STEP 1]

Form PHMSA F 1000.1 Pg. 1 of7 Reproduction of this form is permitted.

Notice: This report is required by 49 CFR Parts 191 and 195. Failure to report may result in a civil penal ty not to exceed $100,000 for each violation for each day the violation continues up to a maximwn of$1 ,000,000 as provided in 49 USC 60122.

Form Approved OMB No. 213 7-0627

Expiration Date: 1213l/20 14

STEP 2 - ENTER DESCRIPTION OF PIPELINES AND/OR FACILITIES

The questions in this STEP allow PHMSA to accurately portray the scope and nature of the pipelines and/or facilities covered by this particular OP/0 Assignment Request and will also be used by PHMSA for their inspection planning.

1. The pipelines and/or facilities covered by this OPID Assignment Request are associated with the following types of facili ties and transport the following types of commodities: (select all that apply) (Complete STEPS 2 and 3 once for each top level facility type in this question that is included in this OP/0 Assignment Request.)

0 LNG Plant(s) I Facility(ies)

0 LNG Storage

c Gas Distribution

0 Natural Gas

0 Propane Gas

D Other Gas --> Name:

12) Gas Transmission

~ Gas Transmission

D Natural Gas

D Propane Gas

D Synthetic Gas

D Hydrogen Gas

0 Other Gas --> Name: Chlorine

0 Gas Storage Facilities--> Total Number:

0 Gas Gathering

0 Hazardous Liquid

Hazardous Liquid Trunkline (regulated non-gathering)

0 Crude Oil

0 Refined and/or Petroleum Product (non-HVL)

0 HVL or Anhydrous Ammonia

Anhydrous Ammonia

LPG (Liquefied Petroleum Gas) I NGL (Natural Gas Liquid)

Other HVL -> Name:

0 C02 (Carbon Dioxide)

0 Biofuel/ Alternative Fuel (including ethanol blends, but excluding Fuel Grade Ethanol)

0 Fuel Grade Ethanol (a lso referred to as Neat Ethanol)

0 Regulated Hazardous Liquid Gathering

0 Hazardous Liquid Breakout Tanks-> Tota l Number:

Form PHMSA F 1000.1 Repraductio11 of this form is permitted_

Pg. 2 of7

Notice: This report is required by 49 CFR Parts 191 and 195. Failure to report may result in a civi l penalty not to exceed $ 100,000 for each violation for each day the violation continues up to a maximum of $ 1,000,000 as provided in 49 USC 60122.

Farm Approved OMB No. 2137-0627

Exp iration Date: 12/31 /2014

2. Will any single pipeline or pipeline facili ty included in this OPID Assignment Request be subject to BOTH 49 CFR Part 192 AND 49 CFR Part 195 due to the planned transportation of commodities which are subject to both Parts? El No 0 Yes [STEP 2 continued]

3. For the top level pipeline and/or facility type selected in STEP 2, Question 1, complete the following:

For Gas Transmission , the pipelines and/or facilities covered by this OPID Assignment Request are: (select Interstate and/or Intrastate, and complete Questions 3a-j for each set of Interstate assets and/or Intrastate assets, and for each selection of Gas Transmission facilities.)

Intrastate

0 Onshore

3a. Approximate number of regulated transmission/trunkline pipeline miles: 1 miles

3b. List all of the States and Counties in which these pipelines are physically located:

I State 1: TN Counties BRADLEY I

3c. Approximate number of regulated Hazardous Liquid gathering miles

3d . List all of the States and Counties in which these Hazardous Liquid gathering lines are physically located:

3e . List all of the States and Counties in which other facilities (including storage/breakout tanks) are physically located, if different than the States and Counties listed in Questions 3b or 3d above:

4. Provide a brief and general description of the pipelines and/or facilities covered by this OPID Assignment Request. Describe each second level selection from STEP 2, Question 1 separately.

In addition to the information provided below, Operators are encouraged to provide a general overview map (or maps) depicting the approximate geographic location of the pipelines and/or facilities covered by this OP/0 Assignment Request. Gas Transmission Pipeline Description: Wacker Polysilicon North America, LLC (Wacker) manufacturing facility will

receive gaseous chlorine manufactured and transported by Olin Chemical (Olin) via an above ground pipeline. The pipeline exits Olin's manufacturing plant and travels approximately one mile on a piperack into Wacker's manufacturing plant. The pipeline travels underneath a public roadway (Lower River Road) via a box culvert. This public road exists between the two facili ties and is the only location where the pipeline is not located on company property of either party.

Form PHMSA F 1000.1 Pg. 3 of7 Reproducthm of this form i.~ permitted.

Notice: This report is required by 49 CFR Parts 191 and 195. Failure to report may result in a civil penalty not to exceed $ 100,000 for each violation for each day tbe violation continues up to a maximum of $ 1,000,000 as provided in 49 USC 60 122.

Form Approved OMB No. 2137-0627

Expiration Date: 12/31/20 14

STEP 3 - PROVIDE PHMSA-REQUIRED PIPELINE SAFETY PROGRAM OR LNG SAFETY PROGRAM INFORMATION

Sometimes, existing pipelines, pipeline segments, pipeline facilities, or LNG Facilities are covered under a common PHMSA-required pipeline safety program or LNG safety program which also involves other assets covered by additional OP/Ds. (These common safety programs are sometimes referred to as "umbrella" safety programs.) This STEP serves to notify PHMSA of these relationships so that compliance performance can be accurately portrayed, as well as to facilitate PHMSA 's resource planning and preparation in the conduct of inspections of these PHMSA-required safety programs.

Gas Transmission

1. Are the pipelines and/or facilities covered by this OPID Assignment Request included with other OPIDs for the purposes of compliance with one or more PHMSA-required pipeline safety program(s) or LNG safety program(s)? (select only one)

D Not known at this time . (Note: The Operator must submit an Operator Registry Notification informing PHMSA of the primary responsibility for managing or administering these PHMSA-required safety programs within 60 days after they are known. Operators should note that many of these programs are required to be in place before initial operations of the pipelines and/or facili ties commence.)

No, the pipelines and/or facilities covered by this OPID Assignment Request have their own independent PHMSA-required safety programs which include no other OPIDs for the following, when applicable:

[For ALL facilities] Anti-Drug Plan and Alcohol Misuse Plan (199.101, 199.202)

[For Gas Distribution, Gas Gathering, Gas Transmission, and Hazardous Liquid Pipeline Facilities] Procedure Manual for Operations, Maintenance, and Emergencies (192.605, 192.615, 195.402); Damage Prevention Program (192 .614, 195.442); Public Awareness/Education Program (192.616, 195.440); Control Room Management Proced ures (192 .631 , 195.446); Operator Qualification Program (192.805, 195.505); and , Integrity Management Program (192.907 , 192.1005, 195.452).

[For Hazardous Liquid Pipeline Facilities ONLY] Response Plan for Onshore Oi l Pipelines (or Alternative State Plan) (194.1 01).

[For LNG Facilities ONLY] LNG Plans & Procedures (193 .2017).

[STEP 3, Question 1 continued]

Form PHMSA F 1000.1 Pg. 4 of7 Reproduction of this form is permitted.

No tice: This report is required by 49 CFR Parts L 9 L and L 95. Failure to report may result in a civi l penalty not to exceed $ 100,000 fo r each violation for each day the violation continues up to a maximum of $1 ,000,000 as provided in 49 USC 60 122.

Form Approved OMB No. 2lJ7-0627

Expiration Date: 12/31/2014

D

[End STEP 3)

Yes, the pipelines and/or facilities covered by this OPID Assignment Request have one or more PHMSA-required pipeline safety program(s) or LNG safety program(s) that also apply to pipeline assets with other OPID numbers for the purposes of compliance with PHMSA regulations.

If Yes, please list the Operator-designated "primary" OPID for each common PHMSA-required pipeline safety program or LNG safety program associated with this OPID Assignment Request. Those programs not selected will be considered to be either not required or independent programs which cover only the pipelines and/or facil ities covered by this OPID Assignment Request: (select all that apply)

1 a. Anti-Drug Plan and Alcohol Misuse Plan (199.1 01 , 199.202) OPID # 0 ISP 0 Unknown

1 b. Procedure Manual for Operations, Maintenance, and Emergencies (192.605, 192.615, 195.402) OPID # 0 ISP 0 Unknown

1c. Damage Prevention Program (192.614, 195.442) OPID # 0 ISP 0 Unknown

1d. Public Awareness/Education Program (192.616, 195.440) OPID # 0 ISP 0 Unknown

1e. Control Room Management Procedures (1 92.631, 195.446) OPID # 0 ISP 0 Unknown

1f. Operator Qualification Program (192.805, 195.505 OPID# 0 ISP Unknown

1g. Integrity Management Program (192 .907, 1 92 . 100~195.452)

OPID # 0 ISP u Unknown

1h. Response Plan for Onshore Oil Pipelines (or Alternative State Plan) (194 .101) OPID # 0 ISP 0 Unknown

1 i. LNG Plans & Procedures (193 .2017) OPID# 0 ISP 0 Unknown

Form PHMSA F 1000.1 Pg. 5 of7 R eproduction ofthi.,· form is permitted.

Notice: This report is required by 49 CFR Parts 191 and 195. Failure to report may result in a civi l penalty not to exceed $100,000 fo r each violation for each day the violat ion continues up to a maximum of$1,000,000 as provided in 49 USC 601 22.

Form Approved OMB No. 213 7-0627

Exp iration Date: 12/31/2014

This STEP ensures that PHMSA has the contact information it needs for the basic STEP 4 - PROVIDE CONTACT INFORMATION forms of Agency-Operator interaction that may occur.

1. Operato r contact overseeing compl iance with 49 CFR Parts 191-199, i.e. the primary contact for regulatory issues:

Name: Last: Copeland First: Jeremy MI : Q Title: Environmental Manager Address :

Street/P.O. Box: 553 MCBRYANT RD., PO BOX 446 , City: CHARLESTON State/Province: TN Zip/Postal Code : 37310

Phone: 14231780-7953 E-mail: ieremv.cooeland@wacker.com

2. Operator co ntact f or info rmation pertaining to PHMSA's inspection scheduling, if d ifferent from above: (Provide one contact for each PHMSA Regional Office where pipelines and/or facilities covered by this OP/0 Assignment Request are physically located)

PHMSA Region: N/A

Name: Last Copeland First Jeremy MIQ

Title: Environmental Manager Address :

Street/P.O. Box: 553 MCBRYANT RD., PO BOX 446 , City: CHARLESTON State/Province: TN Zip/Posta l Code: 3731 0

Phone: {423}780-7953 E-mail: jeremy.copeland@wacker.com

3. 24n Operator contact for emergency situations (natural disasters , national emergencies, security threats, extreme weather events, etc.}:

Name: Last: King First: Dan Ml : Title: Emergency Prepardeness Manager Address:

Street/P.O. Box: 553 MCBRYANT RD., PO BOX 446 ,

City: CHARLESTON State/Province: TN Zip/Postal Code: 37310

Phone: {423}780-8150 E-mail: dan.king@wacker.com

4. 24n Operator phone number for normal operations: Phone: {423}310-3874

5. 24n Operator Control Center phone number: Phone: {423}829-7106

6. Operator's Senior Executive Official :

Name: Last: Bachhuber First: Konrad Ml: Title: Vice-President & Site Manager Address:

Street/P.O. Box: 553 MCBRYANT RD., PO BOX 446 ,

City: CHARLESTON State/Province: TN Zip/Postal Code: 37310

Phone: {423}780-8800 E-mail : konrad.bachhuber@wacker.com

Form PHMSA F 1000.1 Pg. 6 of7 R eproduction ojthi.1-jorm is p ermitted.

Notice: This report is required by 49 CFR Parts 191 aod 195. Failure 10 report may result in a civil penally not to exceed $ 100,000 for each violation for each day the violation continues up to a maximum of$ 1,000,000 as provided in 49 USC 60 122.

7. Operator contact for information pertaining to NPMS submissions:

Name: Last: Copeland First: Jeremv Ml: Q Title: Environmental Manager Address:

Street!P.O. Box: 553 MCBRYANT RD .. PO BOX 446 ,

City: CHARLESTON State/Province: TN Zip/Postal Code: 37310

Phone: (423)780-7953 E-mail : jeremv.copeland@wacker.com

Fonn Approved OMB No. 2137-0627

Expiration Date: 12/31120 14

8. Operator contact responsible for assuring compliance with DOT's Anti-Drug and Alcohol Misuse regulations (49 CFR 199):

Name: Last: Burk First: Erika Ml : Title: Director of Human Resources Address :

Street!P. O. Box: 553 MCBRYANT RD .. PO BOX 446 , City: CHARLESTON State/Province: TN Zip/Postal Code: 37310

Phone: (423)780-8301 E-mail : erika.burk@wacker.com

9. User Fee contact:

Name: Last: Copeland First: Jeremy Ml: Q Title: Environmental Manager Address:

Street!P.O. Box: 553 MCBRYANT RD., PO BOX 446 ,

City: CHARLESTON State/Province: TN Zip/Postal Code: 37310

Phone: (423)780-7953 E-mail : jeremy.copeland@wacker.com

[End STEP 4)

Form PHMSA F 1000.1 Reproduction of this form is permitted.

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